Ezel / IRS Rulings / 201103049

CCA 201103049: Counsel addresses designating a tax matters partner for a prior year

Number
201103049
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Tax Matters Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
December 15, 2010
Publicly released
January 21, 2011
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2011, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2011
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel advised that a partnership may designate a current partner as its tax matters partner for a prior year. The advice relies on Treas. Reg. § 301.6231(a)(7)-1(b)(1)(ii) and § 301.6231(a)(7)-1(f). The determination addresses the timing and eligibility of the designation under the partnership tax rules.

Ruling snapshot

  • Question: May a partnership designate a current partner as tax matters partner for a prior year?
  • Outcome: Advice given
  • Key authorities: IRC § 6231; Treas. Reg. § 301.6231(a)(7)-1(b)(1)(ii), (f)

Full text (IRS public release)

ID: CCA_2010121511585537 Number: 201103049
Release Date: 1/21/2011
Office: ----------
UILC: 6231.07-00

From: -------------------
Sent: Wednesday, December 15, 2010 11:59:30 AM
To: -------------------
Cc: -----------
Subject: RE: 872-P - ----

The partnership can designate a current partner to be TMP for a prior year under Treas. Reg.
301.6231(a)(7)-1(b)(1)(ii) and -1(f). ---------------------------------------------------------------------------------------------
----------

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